Privacy Policy

Who we are

The data controller is Emma van Dijkum, trading as Product Leadership Coaching. We are based in Girona, Spain. VAT number ESB16368524. Email: emma@product-leadership-coaching.com. Full postal address available on request.

We follow the EU General Data Protection Regulation (GDPR), the Spanish data protection law (Ley Orgánica 3/2018, LOPDGDD) and, for clients and visitors in the United Kingdom, the UK GDPR.

What we collect

• Contact and enquiry details: name, email, job title, company, LinkedIn profile and anything you tell us when you complete the diagnostic, download a resource or contact us.
• Booking details: name, email, the time you booked and answers you give when booking a call through Calendly.
• Coaching data: notes, recordings, transcripts and materials from coaching sessions, if you are a client.
• Billing details: company name, address, VAT number and payment records.
• Website usage data: see "Analytics" below.

Why we use it and our legal basis

• To reply to enquiries, send resources you asked for and arrange calls (your request and our legitimate interest).
• To deliver coaching and advisory services (performance of a contract).
• To invoice and keep accounting records (legal obligation under Spanish tax law).
• To occasionally follow up about our services with people who have contacted us (legitimate interest; you can opt out at any time).
• To understand how the website is used and improve it (legitimate interest and, where required, consent).

Coaching sessions and AI tools

With client agreement, sessions may be recorded and transcribed. We use AI-supported tools (such as Notion, ChatGPT, Claude and Granola) for note-taking, summarising and spotting themes. We configure these tools to limit use of client data for model training where possible. You can opt out of recording or AI-supported processing at any time without affecting the service.

We may use fully anonymised themes and stories in public content such as LinkedIn posts and our newsletter. Nothing that could reasonably identify you, your organisation or anyone discussed will be included, and you can opt out in writing at any time.

Who we share data with

We never sell personal data. We share it only with service providers that help us run the business:

• Google (Workspace email, Google Sheets for our contact list, Google Analytics)
• Calendly (call booking)
• Substack (newsletter, if you subscribe there)
• Lovable (website hosting and visitor analytics)
• The AI and note-taking tools listed above
• Our accountant and tax advisers, and authorities where the law requires it

International transfers

Some providers are based in the United States or elsewhere outside the EU. Where data leaves the EU or UK, we rely on adequacy decisions (including the EU-US Data Privacy Framework) or Standard Contractual Clauses.

Analytics

Google Analytics 4 uses cookies to measure visits, which pages are viewed and key actions such as booking a call, downloading a resource or completing the diagnostic. Google receives this data. For visitors in the EU/EEA, the UK, Switzerland and Quebec, Google Analytics sets no cookies unless you accept them in our cookie banner. You can change your choice at any time using the Cookie settings link at the bottom of every page; it is saved in your browser for up to 12 months. If your browser sends Global Privacy Control, analytics cookies stay off.

Lovable visitor analytics uses no cookies, stores nothing on your device, does not keep IP addresses and does not identify visitors. It records the pages visited, where visitors came from, their country, browser, operating system and device type, how long they stay, how fast pages load and errors for every visitor. Clicks and other actions are recorded only once you accept analytics in the cookie banner (in the regions above), and never if your browser sends Global Privacy Control. Elsewhere they are recorded unless you reject. Detailed data is kept for 90 days and daily summaries for a year. Lovable collects this data for us. Lovable's privacy policy explains how it handles it.

Booking widgets from Calendly may set their own cookies when you use them.

No advertising or retargeting

We do not use advertising cookies, tracking pixels, retargeting or remarketing, and we do not build advertising audiences from your data. Analytics is used only to understand how the website is used and improve it. We never sell or rent personal data.

How long we keep it

• Enquiries and leads: up to two years after our last contact.
• Coaching data: no longer than two years after the engagement ends.
• Invoices and accounting records: as long as Spanish law requires (usually six years).

Your rights

You can ask to access, correct, delete, restrict or move your data, object to its use, or withdraw consent at any time. Email emma@product-leadership-coaching.com and we will reply within one month. You can also complain to the Spanish data protection authority, the Agencia Española de Protección de Datos, or your local authority (in the UK, the ICO).

Security

We use reputable providers, access controls and encrypted connections to protect personal data.

Changes

We may update this policy. The date at the top shows the latest version.